Making Sense of ETF Share Class Applications
Introduction
Pending Applications
Types of Relief
Conditions to Relief
One of the most significant issues facing the asset management industry today is whether the U.S. Securities and Exchange Commission (“SEC”) will permit more investment companies to offer classes of mutual fund shares and classes of exchange-traded shares. Numerous asset managers and fund complexes have pending exemptive applications with the SEC to offer exchange-traded funds (“ETFs”) as a share class within a multiple share class structure (“ETF share class”). These applications seek the regulatory relief necessary to provide investors with access to a fund’s investment strategy through either a mutual fund share class or an ETF share class. While one asset manager has utilized this unique multiple share class structure for almost 25 years, the potential for other asset managers to offer funds with this same structure could revolutionize the fund industry in the future.
In a first-of-its-kind report, Stradley Ronon provides an in-depth, data-driven analysis of over 50 ETF share class applications that are currently pending and the conditions proposed by each application. We hope the report provides the fund industry with a key resource to easily assess and access each ETF share class application and track developments over time.
Stradley Ronon is collaborating with clients to determine the benefits of the ETF share class structure for their funds, seek the necessary exemptive relief, and develop the internal processes necessary to implement ETF share class relief.
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Although SEC approval of exemptive relief to permit widespread use of the ETF share class structure would be a dramatic development, the ETF share class structure actually has been in the U.S. market for almost 25 years.
In 2000, the Commission granted an exemptive order to The Vanguard Group, Inc. (“Vanguard”) to permit Vanguard to offer certain index-based open-end management investment companies with mutual fund classes and exchange-traded classes. With this unique structure, one fund could offer both mutual fund shares and exchange-traded shares. Vanguard obtained additional SEC orders in 2003 and 2007 that allowed Vanguard to utilize this approach for more of its index-based funds. As a result, many investors already invest in ETFs through ETF share classes.
Funds with Pending Applications
53 applications are currently pending before the SEC (as of March 25, 2025) and can be accessed through the boxes below (presented alphabetically based on the first applicant listed on each application). Note that some additional applications have been filed, but were later deemed withdrawn by the SEC when the applicants did not respond to SEC staff comments on the applications. Withdrawn applications are not included below.
Toggle the funds alphabetically, and click on individual funds to learn more
Types of Relief
Some applications specify that the adviser would like to add ETF classes to mutual funds. Other applications state that the adviser would like to add mutual fund classes to ETFs. The majority of applications seek both options.
Regardless of the variations noted above, the core arguments in the pending applications are generally similar.
Click on a slice to see the full breakdown
Benefits of Structure
The ETF share class structure can offer multiple benefits to funds and fund investors, such as allowing the fund to leverage economies of scale and potentially provide investors with better performance. The structure will also provide investors with the choice of obtaining their desired investment exposure through a mutual fund share class or an ETF share class.
AB Municipal Income Fund, Inc.
AB Municipal Income Fund, Inc.
File Date
5/1/2024
File Number
812-15570
ETF + MF
53
Total Applications
MF + ETF
Both MF + ETF and ETF + MF
Both MF + ETF and ETF + MF
Analysis of Conditions Proposed by Applications
Each of the applications for relief to offer ETF share classes proposes certain conditions to the relief. These are key commitments that the applicants make to the SEC in order to address SEC policy concerns. The chart below reflects how many applications propose various conditions. A summary of each type of condition can be found by hovering over each condition title listed below.
Click on a condition to see what they mean and which funds apply
AMG Funds
ALPS ETF Trust
BNY Mellon Investment Funds
Cash Account Trust: Deutsche DWS Funds
DoubleLine Funds Trust
Franklin Templeton ETF Trust
Guinness Atkinson Funds
Hartford Mutual Funds, Inc.
6c-11 Compliance
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
A Report on Pending Requests for SEC Relief
53
Total number of applications pending
BNY Mellon Investment Funds
A - F
G - N
O - Z
A - F
Aristotle Fund Series Trust
AMG Funds
Allspring Funds Trust
AB Municipal Income Fund, Inc.
First Eagle Funds
Fidelity Hastings Street Trust
F/m Investments LLC
DFA Investment Dimensions Group Inc.
Cash Account Trust: Deutsche DWS Funds
BondBloxx ETF Trust
First Trust Series Fund
First Trust Exchange-Traded Fund
G - N
O - Z
30
Both MF + ETF and ETF + MF
First Eagle Funds
19
MF + ETF
MF + ETF
ETF + MF
4
ETF + MF
MF + ETF = Mutual fund adding ETF share class
ETF + MF = ETF adding mutual fund share class
Both MF + ETF and ETF + MF = Adding ETF share class to mutual fund and adding mutual fund share class to ETF
Relief for Active or Index Funds
Some applications have specified that the multiple-share class structure would apply to actively managed funds only. Other applications have requested that the relief would apply only to index-based funds. The majority of applications seek the flexibility to adopt the multiple-class structure regardless of whether the funds are actively managed or index-based.
Click on a slice to see the full breakdown
53
Total Applications
Index
Active
Active + Index
36
Active + Index
Active + Index
6c-11 Compliance
50
40
30
20
10
0
Active
13
Active
4
Index
Index
Cash Baskets
Allocate Brokerage Expenses
Semi-Transparent ETFs
Marketing
18f-3 Compliance
Adviser Initial Reports to Board
Periodic Review; Board Evalutation
Disclosure
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
The exchange-traded share class would generally conduct its operations in compliance with the requirements of the ETF Rule under the 1940 Act.
The exchange-traded share class would generally conduct its operations in compliance with the requirements of the ETF Rule under the 1940 Act.
The fund would generally comply with the requirements for traditional multiple-class funds contained in Rule 18f-3 under the 1940 Act, other than with respect to certain differences explained in the applications.
ETF classes generally will sell and redeem shares through cash transactions rather than in-kind transactions.
The adviser will furnish to the board a written report to assist the board in its initial consideration of adding an ETF or mutual fund class.
Brokerage expenses that are attributable to either the mutual fund class or the ETF class will be allocated to that class.
With respect to ETF share classes operating in reliance on SEC exemptive orders that do not require full portfolio disclosure (“semi-transparent ETFs”), funds will disclose their portfolios only as required by the exemptive orders rather than the ETF Rule.
The registration statement will include appropriate disclosure regarding the characteristics and any significant risks associated with the multi-class structure.
ETF shares will not be marketed as a mutual fund investment. Some versions of this condition also commit that any advertising material that describes the purchase or sale of shares by the ETF share class (in large aggregations called “Creation Units”) or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
The board will, at specified intervals, review the structure of the fund and appropriateness of the multiple class structure.
Franklin Templeton ETF Trust
NuShares ETF Trust
Northern Funds
Natixis Funds Trust
MORGAN STANLEY INSTITUTIONAL FUND TRUST
Metropolitan West Funds: TCW Funds
Lord, Abbett & Co. LLC
John Hancock Investment Trust
Janus Investment Fund
J.P. Morgan Investment Management Inc.
INVESTMENT MANAGERS SERIES TRUST
Invesco Exchange-Traded Fund Trust
IMPAX FUNDS SERIES TRUST
NuShares ETF Trust
File Date
10/18/2024
File Number
812-15644
Lord, Abbett & Co. LLC
LORD, ABBETT & CO. LLC LORD ABBETT AFFILIATED FUND, INC. LORD ABBETT BOND DEBENTURE FUND, INC. LORD ABBETT DEVELOPING GROWTH FUND, INC. LORD ABBETT MID CAP STOCK FUND, INC. LORD ABBETT MUNICIPAL INCOME FUND, INC. LORD ABBETT RESEARCH FUND, INC. LORD ABBETT GLOBAL FUND, INC. LORD ABBETT SERIES FUND, INC. LORD ABBETT SECURITIES TRUST LORD ABBETT INVESTMENT TRUST LORD ABBETT TRUST I
File Date
12/23/2024
File Number
812-15680
LORD ABBETT BOND DEBENTURE FUND, INC. LORD ABBETT MUNICIPAL INCOME FUND, INC. LORD ABBETT GLOBAL FUND, INC. LORD ABBETT TRUST I LORD ABBETT INVESTMENT TRUST LORD ABBETT SERIES FUND, INC.
File Date
12/23/2024
File Number
812-15681
Janus Investment Trust
INVESTMENT MANAGERS SERIES TRUST
Invesco Exchange-Traded Fund Trust
INVESCO EXCHANGE-TRADED FUND TRUST INVESCO EXCHANGE-TRADED FUND TRUST II INVESCO INDIA EXCHANGE-TRADED FUND TRUST INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST INVESCO ACTIVELY MANAGED EXCHANGE-TRADED COMMODITY FUND TRUST INVESCO EXCHANGE-TRADED SELF-INDEXED FUND TRUST INVESCO CAPITAL MANAGEMENT LLC AIM COUNSELOR SERIES TRUST (INVESCO COUNSELOR SERIES TRUST) AIM EQUITY FUNDS (INVESCO EQUITY FUNDS) AIM FUNDS GROUP (INVESCO FUNDS GROUP) AIM GROWTH SERIES (INVESCO GROWTH SERIES) AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS) AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS) AIM INVESTMENT SECURITIES FUNDS (INVESCO INVESTMENT SECURITIES FUNDS) AIM SECTOR FUNDS (INVESCO SECTOR FUNDS) AIM TAX-EXEMPT FUNDS (INVESCO TAX-EXEMPT FUNDS) AIM TREASURER’S SERIES TRUST (INVESCO TREASURER’S SERIES TRUST) AIM VARIABLE INSURANCE FUNDS (INVESCO VARIABLE INSURANCE FUNDS) SHORT-TERM INVESTMENTS TRUST INVESCO MANAGEMENT TRUST
File Date
12/16/2024
File Number
812-15672
BNY Mellon Investment Funds
BNY Mellon Investment Funds VII, Inc.
File Date
3/13/2025
File Number
812-15723
AMG Funds
AMG Funds I
AMG Funds II AMG Funds III AMG Funds IV AMG Funds LLC
File Date
7/2/2024
File Number
812-15599
ARISTOTLE FUNDS SERIES TRUST
ARISTOTLE FUNDS SERIES TRUST
File Date
12/13/2024
File Number
812-15671
BlackRock Funds
BlackRock Funds I
BlackRock Funds II BlackRock Funds V BlackRock Funds III
File Date
10/30/2024
File Number
812-15652
BondBloxx ETF Trust
BONDBLOXX ETF TRUST
File Date
12/4/2024
File Number
812-15665
Cash Account Trust: Deutsche DWS Funds
DEUTSCHE DWS ASSET ALLOCATION TRUST DEUTSCHE DWS GLOBAL/INTERNATIONAL FUND, INC DEUTSCHE DWS INCOME TRUST DEUTSCHE DWS INSTITUTIONAL FUNDS DEUTSCHE DWS INTERNATIONAL FUND, INC. DEUTSCHE DWS INVESTMENT TRUST DEUTSCHE DWS INVESTMENTS VIT FUNDS DEUTSCHE DWS MARKET TRUST DEUTSCHE DWS MONEY FUNDS DEUTSCHE DWS MONEY MARKET TRUST DEUTSCHE DWS MUNICIPAL TRUST DEUTSCHE DWS PORTFOLIO TRUST DEUTSCHE DWS SECURITIES TRUST DEUTSCHE DWS STATE TAX-FREE INCOME SERIES DEUTSCHE DWS TAX FREE TRUST DEUTSCHE DWS VARIABLE SERIES I DEUTSCHE DWS VARIABLE SERIES II INVESTORS CASH TRUST DBX ETF TRUST
File Date
12/20/2024
File Number
812-15679
DFA Investment Dimensions Group Inc.
DFA Investment Dimensions Group Inc. Dimensional Investment Group Inc. Dimensional Fund Advisors LP
File Date
7/12/2023
File Number
812-15484
F/m Investments LLC
RBB FUND, INC.
File Date
8/22/2023
File Number
812-15501
Fidelity Hastings Street Trust
Fidelity Management & Research Co LLC
File Date
10/24/2023
File Number
812-15517
First Eagle Funds
FIRST EAGLE FUNDS
File Date
12/31/2024
File Number
812-15683
Franklin Templeton ETF Trust
Legg Mason Partners Investment Trust Franklin Advisors Inc. Franklin Advisory Services LLC Franklin Templeton Investment Management Ltd Franklin Templeton Fund Adviser, LLC
File Date
6/13/2024
File Number
812-15588
GMO Trust
GMO Trust
File Date
5/23/2024
File Number
812-15577
Impax Funds Series Trust
IMPAX FUNDS SERIES TRUST I
IMPAX FUNDS SERIES TRUST III
File Date
09/20/2024
File Number
812-15631
INVESTMENT MANAGERS SERIES TRUST
File Date
1/15/2025
File Number
812-15691
J.P. Morgan Investment Management Inc.
JPMorgan Trust I
JPMorgan Trust II
JPMorgan Trust IV J.P. Morgan Exchange-Traded Fund Trust
File Date
11/25/2024
File Number
812-15663
File Date
11/25/2024
File Number
812-15662
JPMorgan Trust I JPMorgan Trust II JPMorgan Trust IV J.P. Morgan Exchange-Traded Fund Trust J.P. Morgan Fleming Mutual Fund Group, Inc. J.P. Morgan Mutual Fund Investment Trust Undiscovered Managers Fund
JANUS INVESTMENT FUND
File Date
7/31/2024
File Number
812-15607
John Hancock Investment Trust
JOHN HANCOCK INVESTMENT TRUST
File Date
9/26/2024
File Number
812-15637
Metropolitan West Funds: TCW Funds
TCW FUNDS, INC. TCW ETF TRUST TCW Investment Management Co LLC Metropolitan West Asset Management, LLC
File Date
3/20/2024
File Number
812-15556
MORGAN STANLEY INSTITUTIONAL FUND TRUST
MORGAN STANLEY INSTITUTIONAL FUND TRUST
File Date
1/29/2024
File Number
812-15542
Natixis Funds Trust
NATIXIS FUNDS TRUST I NATIXIS FUNDS TRUST II NATIXIS FUNDS TRUST IV GATEWAY TRUST LOOMIS SAYLES FUNDS I LOOMIS SAYLES FUNDS II NATIXIS ETF TRUST NATIXIS ETF TRUST II
File Date
9/12/2024
File Number
812-15627
Northern Funds
NORTHERN FUNDS
File Date
5/14/2024
File Number
812-15573
Nuveen Fund Advisors, LLC Nuveen Municipal Trust Nuveen Multistate Trust I Nuveen Multistate Trust II Nuveen Multistate Trust III Nuveen Multistate Trust IV Nuveen Investment Trust Nuveen Investment Trust II Nuveen Investment Trust III Nuveen Investment Trust V Nuveen Investment Funds, Inc. Nuveen Asset Management, LLC
Virtus Alternative Solutions Trust
Touchstone Funds Group Trust
Tidal ETF Trust
Thrivent Mutual Funds
Thornburg Investment Trust
SPDR Series Trust
Shelton Funds
SEI Investments Global Funds Services
Segall Bryant & Hamill Trust
Schwab Strategic Trust
Principal Funds, Inc.
PIMCO Funds
PGIM Investments LLC
PFS Funds
Palmer Square Funds Trust
Virtus Alternative Solutions Trust
VIRTUS ASSET TRUST VIRTUS EQUITY TRUST Virtus Investment Advises, Inc. Virtus Fund Advisers, LLC Virtus Alternative Invetments Advisers, Inc. VIRTUS EVENT OPPORTUNITES TRUST VIRTUS INVESTMENT TRUST VIRTUS OPPORTUNITIES TRUST VIRTUS STRATEGY TRUST VIRTUS VARIABLE INSURANCE TRUST THE MERGER FUND® THE MERGER FUND®VL
File Date
8/28/2024
File Number
812-15619
Touchstone Funds Group Trust
TOUCHSTONE STRATEGIC TRUST TOUCHSTONE VARIABLE SERIES TRUST Touchstone Advisors Inc.
File Date
5/31/2024
File Number
812-15582
Tidal ETF Trust
TIDAL ETF TRUST
File Date
10/16/2024
File Number
812-15643
Thrivent Mutual Funds
THRIVENT ETF TRUST Thrivent Asset Management, LLC
File Date
8/28/2024
File Number
812-15621
Thornburg Investment Trust
THORNBURG ETF TRUST
File Date
1/8/2025
File Number
812-15688
SPDR Series Trust
SPDR INDEX SHARES FUNDS
File Date
11/1/2024
File Number
812-15653
Shelton Funds
SCM TRUST
File Date
9/11/2024
File Number
812-15626
SEI Investments Global Funds Services
SEI INVESTMENTS GLOBAL FUNDS SERVICES
File Date
12/12/2024
File Number
812-15669
Schwab Strategic Trust
The Charles Schwab Family of Funds Schwab Annuity Portfolios Schwab Capital Trust Schwab Investments Laudus Trust
File Date
6/17/2024
File Number
812-15589
Principal Funds, Inc.
PRINCIPAL FUNDS, INC.
File Date
6/20/2024
File Number
812-15592
T. Rowe Price Index Trust, Inc. T. Rowe Price Integrated Equity Funds, Inc. T. Rowe Price Exchange-Traded Funds, Inc.
File Date
8/14/2024
File Number
812-15613
PGIM Investments LLC
The Prudential Investment Portfolios, Inc. Prudential Investment Portfolios 2 Prudential Investment Portfolios 3 Prudential Investment Portfolios 4 Prudential Investment Portfolios 5 Prudential Investment Portfolios 6 Prudential Investment Portfolios 7 Prudential Investment Portfolios 8 Prudential Investment Portfolios 9 Prudential Investment Portfolios, Inc. 10 Prudential Investment Portfolios 12 Prudential Government Money Market Fund, Inc. Prudential Investment Portfolios, Inc. 14 Prudential Investment Portfolios, Inc. 15 Prudential Investment Portfolios 16 Prudential Investment Portfolios, Inc. 17 Prudential Investment Portfolios 18 Prudential Global Total Return Fund, Inc. Prudential Jennison Blend Fund, Inc. Prudential Jennison Mid-Cap Growth Fund, Inc. Prudential Jennison Natural Resources Fund, Inc. Prudential Jennison Small Company Fund, Inc. Prudential National Muni Fund, Inc. Prudential Sector Funds, Inc. Prudential Short-Term Corporate Bond Fund, Inc. Prudential World Fund, Inc. The Target Portfolio Trust
File Date
4/19/2024
File Number
812-15567
PFS Funds
PFS FUNDS
File Date
9/24/2024
File Number
812-15636
Palmer Square Funds Trust
Palmer Square Funds Trust
File Date
12/19/2024
File Number
812-15677
T. Rowe Price Associates, Inc.
Segall Bryant & Hamill Trust
SEGALL BRYANT & HAMILL TRUST
File Date
10/7/2024
File Number
812-15641
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Impax Funds Series Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Hotchkis and Wiley Funds
Invesco Exchange-Traded Fund Trust
We’re looking to realize the economies of scale that multiple share classes could bring for both mutual fund and new ETF shareholders.”
Gerard K. O’Reilly, Co-Chief Executive Officer and Co-Chief Investment Officer, Dimensional Fund Advisors LP
Background on the ETF Share Class Structure
53 Applications Pending
Asset managers and fund complexes have filed over 50 applications, which primarily contemplate compliance with rule 6c-11 (known as the “ETF Rule”) under the Investment Company Act of 1940 (“1940 Act”), compliance with rule 18f-3 under the 1940 Act (which governs the operations of multiple share class investment companies), and appropriate disclosures. The key differences among applications typically relate to the share class that may be added to an existing fund (e.g., mutual fund or ETF share class), the fund’s investment strategy (e.g., index and/or active), and continued oversight of the ETF share class structure.
Implementation
However, when the SEC adopted the ETF Rule in 2019, the SEC determined not to provide the necessary exemptive relief to allow for ETF share classes as part of the rule. The SEC noted that an ETF class would typically sell and redeem shares on an in-kind basis, while a mutual fund class transacts with shareholders on a cash basis. The SEC explained that these different types of transactions could give rise to differing costs, but with the multi-class structure, all fund shareholders generally bear these costs.
The SEC therefore concluded that share class ETFs should request relief through the exemptive applications process so that the SEC could assess all relevant policy considerations in the context of the facts and circumstances of particular applicants. And thus the stage was set for the current industry effort to obtain ETF share class relief through exemptive applications filed with the SEC. These applications generally seek to address the concerns previously expressed by the SEC when it adopted the ETF rule.
38
Total number of the pending applications that include versions of the four core conditions illustrated in the analysis of conditions bar chart below
However, when the SEC adopted the ETF Rule in 2019, the SEC determined not to provide the necessary exemptive relief to allow for ETF share classes as part of the rule.
Instead, the SEC concluded that share class ETFs should request relief through the exemptive applications process so that the SEC could assess all relevant policy considerations in the context of the facts and circumstances of particular applicants. And thus, the stage was set for the current industry effort to obtain ETF share class relief through exemptive applications filed with the SEC.
Guinness Atkinson Funds
GMO Trust
Hotchkis and Wiley Funds
Hotchkis and Wiley Funds
File Date
1/7/2025
File Number
812-15686
HARTFORD MUTUAL FUNDS, INC
HARTFORD MUTUAL FUNDS, INC THE HARTFORD MUTUAL FUNDS II, INC HARTFORD FUNDS EXCHANGE-TRADED TRUST LATTICE STRATEGIES TRUST
File Date
9/24/2024
File Number
812-15635
Allspring Funds Trust
Allspring Funds Trust
File Date
6/20/2024
File Number
812-15591
First Trust Exchange-Traded Fund
First Trust Exchange-Traded Fund First Trust Exchange-Traded Fund II First Trust Exchange-Traded Fund III First Trust Exchange-Traded Fund IV First Trust Exchange-Traded Fund V First Trust Exchange-Traded Fund VI First Trust Exchange-Traded Fund VII First Trust Exchange-Traded Fund VIII First Trust Exchange-Traded AlphaDEX Fund First Trust Exchange-Traded AlphaDEX Fund II First Trust Advisors L.P. First Trust Portfolios L.P.
File Date
2/6/2025
File Number
812-15698
First Trust Series Fund
First Trust Advisors L.P. First Trust Portfolios L.P.
File Date
2/6/2025
File Number
812-15697
Guinness Atkinson Funds
GUINNESS ATKINSON FUNDS
File Date
10/4/2024
File Number
812-15640
Hotchkis and Wiley Funds
HARTFORD MUTUAL FUNDS, INC.
T. Rowe Price Associates, Inc.
PIMCO Funds
PIMCO Equity Series PIMCO ETF Trust PIMCO Equity Series VIT PIMCO Variable Insurance Trust Pacific Investment Management Company LLC
File Date
2/25/2025
File Number
812-15708
Asset managers and fund complexes should be asking the following questions:
What framework will we use to assess the ETF share class structure?
How will we develop the methodologies necessary to evaluate the multiple factors within this framework?
How will we integrate the operations of a mutual fund share class that generally sells and redeems shares through cash transactions and an ETF share class that generally allows creations and redemptions of shares through in-kind transactions?
How will we coordinate the distribution arrangements and pricing of the respective share classes?
July 12, 2023
Dimensional Fund Advisors LP files with the SEC, and its application stands as the longest pending request for relief
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Managers Series Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (15680)
Lord, Abbett & Co. LLC (15681)
Metropolitan West Funds: TCW Funds
Natixis Funds Trust
Palmer Square Funds Trust
PIMCO Funds
Schwab Strategic Trust
Segall Bryant & Hamill Trust
Shelton Funds
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
AB Municipal Income Fund, Inc.
Allspring Funds Trust
BlackRock
DFA Investment Dimensions Group Inc.
Fidelity Hastings Street Trust
First Trust Series Fund
GMO Trust
Janus Investment Fund
John Hancock Investment Trust
Madison Funds
Northern Funds
PFS Funds
PGIM Investments LLC
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
SEI Investments Global Funds Services
Touchstone Funds Group Trust
BondBloxx ETF Trust
F/m Investments LLC
First Trust Exchange-Traded Fund
SDPR Series Trust
ALPS ETF Trust
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
Cash Account Trust: Deutsche DWS Funds
DoubleLine Funds Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Franklin Templeton ETF Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Managers Series Trust
JPM (812-15662)
Janus Investment Fund
John Hancock Investment Trust
Lord, Abbett & Co. LLC (15680)
Metropolitan West Funds: TCW Funds
Morgan Stanley Institutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
PGIM Investments LLC
PIMCO Funds
Schwab Strategic Trust
Shelton Funds
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
AB Municipal Income Fund, Inc.
Allspring Funds Trust
DFA Investment Dimensions Group Inc.
Fidelity Hastings Street Trust
GMO Trust
Guinness Atkinson Funds
JPM (812-15663)
Palmer Square Funds Trust
PFS Funds
Professional Managed Portfolios: Akre Focus Fund
SEI Investments Global Funds Services
BondBloxx ETF Trust
F/m Investments LLC
Segall Bryant & Hamill Trust
SPDR Series Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
Thrivent Mutual Funds
Tidal ETF Trust
18f-3 Compliance
The fund would generally comply with the requirements for traditional multiple-class funds contained in Rule 18f-3 under the 1940 Act, other than with respect to certain differences explained in the applications.
Adviser Initial Reports to Board
The adviser will furnish to the board a written report to assist the board in its initial consideration of adding an ETF or mutual fund class.
Cash Baskets
ETF classes generally will sell and redeem shares through cash transactions rather than in-kind transactions.
Disclosure
The registration statement will include appropriate disclosure regarding the characteristics and any significant risks associated with the multi-class structure.
Periodic Review; Board Evaluation
The board will, at specified intervals, review the structure of the fund and appropriateness of the multiple class structure.
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
Lord, Abbett & Co. LLC (812-15681)
Janus Investment Fund
J.P. Morgan Investment Management
Allocation of Brokerage Expenses to “Responsible” Class
Brokerage expenses that are attributable to either the mutual fund class or the ETF class will be allocated to that class.
SEI Investments Global Funds Services
Semi-Transparent ETFs
With respect to ETF share classes operating in reliance on SEC exemptive orders that do not require full portfolio disclosure (“semi-transparent ETFs”), funds will disclose their portfolios only as required by the exemptive orders rather than the ETF Rule.
Natixis Funds Trust
Thrivent Mutual Funds
Tidal ETF Trust
T. Rowe Price Associates, Inc.
Marketing
ETF shares will not be marketed as a mutual fund investment. Some versions of this condition also commit that any advertising material that describes the purchase or sale of shares by the ETF share class (in large aggregations called “Creation Units”) or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
AB Municipal Income Fund, Inc.
Professional Managed Portfolios: Akre Focus Fund
Janus Investment Fund
PFS Funds
Board Approval
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
JPM (812-15662)
JPM (812-15662)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Contact Us
If you would like to discuss the findings of this report or ETF share class structures more generally, please don’t hesitate to reach out to us. To subscribe to ongoing industry news and updates from Stradley Ronon, please sign up here.
Michael Mundt, Partner
mmundt@stradley.com
202.419.8403
Brian P. Murphy, Partner
bmurphy@stradley.com
215.564.8036
Eric Purple, Partner
epurple@stradley.com
202.507.5154
Stephen Feinour, Partner
jfeinourjr@stradley.com
215.564.8521
The authors would like to thank the contributions of Stradley Ronon associates Conor Courtney and Katie Gallop.
About Stradley Ronon
Stradley Ronon represents a broad range of ETFs, their investment advisers and/or their independent directors ranging from representations involving three of the four largest ETF groups in the United States, multiple representations of top 30 ETF groups, and representations of startup ETF groups. We guide our clients in navigating the complex regulatory and market environments in which ETFs are developed, launched and operated. We also work with boards of directors on all aspects of the establishment and oversight of ETFs.
Stradley’s deep bench of ETF practitioners includes partners who are actively representing clients on some of the pending applications for ETF share class relief noted above, including the original application filed by Dimensional Fund Advisors LP that has served as a model for most of the subsequent filings by other asset managers. Stradley partners also include a partner who, as an SEC staff member at the time, supervised the review of the original ETF class exemptive orders, as well as another partner who served as an in-house attorney instrumental in implementing that relief.
Board Approval
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
JPM (812-15662)
JPM (812-15662)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
Marketing
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
AB Municipal Income Fund, Inc.
Akre Focus Fund
Janus Investment Fund
PFS
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
Semi-Transparent ETFs
With respect to ETFs operating in reliance on semi-transparent relief, such ETFs will not be required to publish daily portfolio holdings as otherwise required by Rule 6c-11.
Natixis
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
Board Approval
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
JPM (812-15662)
JPM (812-15662)
Lord, Abbett & Co. LLC (812-15680)
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
18f-3 Compliance
To generally mean an applicant’s representation as to compliance with the requirements of Rule 18f-3 and generally include certain approvals to be made by the applicable Board and, where relevant approvals by the Board’s independent directors/trustees.
Thrivent Mutual Funds
Tidal
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Natixis
Northern Funds
NuShares
Palmer Square Funds Trust
PFS
PGIM Investments LLC
PIMCO Funds
Price T. Rowe Associates Inc. / MD
Principal Funds, Inc.
Schwab Strategic Trust
Segall
SEI
GMO Trust
Guinness Atkinson Trust
Hartford
Hotchkis and Wiley Funds
Impax
Invesco
Investment Manager Series Trust
Janus Investment Fund
John Hancock
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BondBloxx ETF Trust
Cash Account Trust
DFA Investment Dimensions Group Inc.
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
Cash Account Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Managers Series Trust
JPM (812-15662)
Janus Investment Fund
Lord, Abbett & Co. LLC (15680)
Lord, Abbett & Co. LLC (15681)
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
AMG Funds
BlackRock Funds
Cash Account Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Franklin Templeton ETF Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Active + Index
Active
AB Municipal Income Fund, Inc.
Akre Focus Fund
Allspring Funds Trust
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
BlackRock Funds
DoubleLine Funds Trust
DOUBLELINE ETF TRUST DOUBLELINE CAPITAL LP DOUBLELINE ETF ADVISER LP DOUBLELINE ALTERNATIVES LP
File Date
3/13/2025
File Number
812-15724
Professionally Managed Portfolios - Akre Focus Fund
Professionally Managed Portfolios - Akre Focus Fund
Akre Capital Management, LLC
File Date
3/4/2025
File Number
812-15713
Tidal ETF Trust
Virtus Alternative Solutions Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Segall Bryant & Hamill Trust
Shelton Funds
SPDR Series Trust
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
GMO Trust
Guinness Atkinson Trust
Hotchkis and Wiley Funds
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15681)
Metropolitan West Funds: TCW Funds
Natixis Funds Trust
NuShares ETF Trust
Palmer Square Funds Trust
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Franklin Templeton ETF Trust
Impax Funds Series Trust
Lord, Abbett & Co. LLC (812-15680)
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
Shelton Funds
SPDR Series Trust
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Metropolitan West Funds: TCW Funds
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
BlackRock Funds
F/m Investments LLC
GMO Trust
Natixis
Thrivent Mutual Funds
Tidal
PFS Funds
Segall Bryant & Hamill Trust
Shelton Funds
SPDR Series Trust
GMO Trust
Guinness Atkinson Trust
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Metropolitan West Funds: TCW Funds
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
First Trust Series Fund
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Metropolitan West Funds: TCW Funds
Segall Bryant & Hamill Trust
Shelton Funds
SPDR Series Trust
BNY Mellon Investment Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Natixis Funds Trust
Northern Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Metropolitan West Funds: TCW Funds
PIMCO Funds
Schwab Strategic Trust
Shelton Funds
T. Rowe Price Associates, Inc.
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Managers Series Trust
JPM (812-15662)
Janus Investment Fund
Lord, Abbett & Co. LLC (15680)
Lord, Abbett & Co. LLC (15681)
AMG Funds
Aristotle Funds Series Trust
BNY Mellon Investment Funds
Cash Account Trust: Deutsche DWS Funds
DoubleLine Funds Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Franklin Templeton ETF Trust
Active + Index
Lord, Abbett & Co. LLC (15680)
Lord, Abbett & Co. LLC (15681)
Shelton Funds
T. Rowe Price Associates, Inc.
Shelton Funds
Shelton Funds
T. Rowe Price Associates, Inc.
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Managers Series Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (15680)
Lord, Abbett & Co. LLC (15681)
Metropolitan West Funds: TCW Funds
AMG Funds
Aristotle Funds Series Trust
BNY Mellon Investment Funds
Cash Account Trust: Deutsche DWS Funds
DoubleLine Funds Trust
First Eagle Funds
Franklin Templeton ETF Trust
Guinness Atkinson Funds
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Hotchkis and Wiley Funds
Both MF + ETF and ETF + MF
MF + ETF
Northern Funds
PFS Funds
PGIM Investments LLC
Principal Funds, Inc.
A - G
H - N
O - Z
Cash Account Trust: Deutsche DWS Funds
DEUTSCHE DWS ASSET ALLOCATION TRUST DEUTSCHE DWS GLOBAL/INTERNATIONAL FUND, INC DEUTSCHE DWS INCOME TRUST DEUTSCHE DWS INSTITUTIONAL FUNDS DEUTSCHE DWS INTERNATIONAL FUND, INC. DEUTSCHE DWS INVESTMENT TRUST DEUTSCHE DWS INVESTMENTS VIT FUNDS DEUTSCHE DWS MARKET TRUST DEUTSCHE DWS MONEY FUNDS DEUTSCHE DWS MONEY MARKET TRUST DEUTSCHE DWS MUNICIPAL TRUST DEUTSCHE DWS PORTFOLIO TRUST DEUTSCHE DWS SECURITIES TRUST DEUTSCHE DWS STATE TAX-FREE INCOME SERIES DEUTSCHE DWS TAX FREE TRUST DEUTSCHE DWS VARIABLE SERIES I DEUTSCHE DWS VARIABLE SERIES II INVESTORS CASH TRUST DBX ETF TRUST
File Date
12/20/2024
File Number
812-15679
AB Municipal Income Fund, Inc.
AB Municipal Income Fund, Inc.
File Date
5/1/2024
File Number
812-15670
Allspring Funds Trust
Allspring Funds Trust
File Date
6/20/2024
File Number
812-15670
AMG Funds I
AMG Funds II AMG Funds III AMG Funds IV AMG Funds LLC
File Date
7/2/2024
File Number
812-15599
ARISTOTLE FUNDS SERIES TRUST
Aristotle Fund Series Trust
ARISTOTLE FUNDS SERIES TRUST
File Date
12/13/2024
File Number
812-15671
BlackRock Funds
BlackRock Funds I
BlackRock Funds II BlackRock Funds V BlackRock Funds III
File Date
10/30/2024
File Number
812-15652
BNY Mellon Investment Funds
BNY Mellon Investment Funds VII, Inc.
File Date
3/13/2025
File Number
812-15723
BondBloxx ETF Trust
BONDBLOXX ETF TRUST
File Date
12/4/2024
File Number
812-15665
DFA Investment Dimensions Group Inc.
DFA Investment Dimensions Group Inc. Dimensional Investment Group Inc. Dimensional Fund Advisors LP
File Date
7/12/2023
File Number
812-15484
DoubleLine Funds Trust
DOUBLELINE ETF TRUST DOUBLELINE CAPITAL LP DOUBLELINE ETF ADVISER LP DOUBLELINE ALTERNATIVES LP
File Date
3/13/2025
File Number
812-15724
DFA Investment Dimensions Group Inc.
DFA Investment Dimensions Group Inc. Dimensional Investment Group Inc. Dimensional Fund Advisors LP
File Date
7/12/2023
File Number
812-15484
F/m Investments LLC
RBB FUND, INC.
File Date
8/22/2023
File Number
812-15501
Fidelity Hastings Street Trust
Fidelity Management & Research Co LLC
File Date
10/24/2023
File Number
812-15517
First Eagle Funds
FIRST EAGLE FUNDS
File Date
12/31/2024
File Number
812-15683
First Trust Exchange-Traded Fund
First Trust Exchange-Traded Fund First Trust Exchange-Traded Fund II First Trust Exchange-Traded Fund III First Trust Exchange-Traded Fund IV First Trust Exchange-Traded Fund V First Trust Exchange-Traded Fund VI First Trust Exchange-Traded Fund VII First Trust Exchange-Traded Fund VIII First Trust Exchange-Traded AlphaDEX Fund First Trust Exchange-Traded AlphaDEX Fund II
File Date
2/6/2025
File Number
812-15698
First Trust Series Fund
First Trust Advisors L.P. First Trust Portfolios L.P.
File Date
2/6/2025
File Number
812-15697
GMO Trust
GMO Trust
File Date
5/23/2024
File Number
812-15577
First Trust Exchange-Traded Fund
First Eagle Funds
Fidelity Hastings Street Trust
F/m Investments LLC
DoubleLine Funds Trust
DFA Investment Dimensions Group Inc.
Cash Account Trust: Deutsche DWS Funds
BondBloxx ETF Trust
BNY Mellon Investment Funds
BlackRock Funds
Aristotle Fund Series Trust
AMG Funds
Allspring Funds Trust
AB Municipal Income Fund, Inc.
First Trust Exchange-Traded Fund
First Trust Exchange-Traded Fund First Trust Exchange-Traded Fund II First Trust Exchange-Traded Fund III First Trust Exchange-Traded Fund IV First Trust Exchange-Traded Fund V First Trust Exchange-Traded Fund VI First Trust Exchange-Traded Fund VII First Trust Exchange-Traded Fund VIII First Trust Exchange-Traded AlphaDEX Fund First Trust Exchange-Traded AlphaDEX Fund II
File Date
2/6/2025
File Number
812-15698
First Eagle Funds
FIRST EAGLE FUNDS
File Date
12/31/2024
File Number
812-15683
Fidelity Hastings Street Trust
Fidelity Management & Research Co LLC
File Date
10/24/2023
File Number
812-15517
RBB FUND, INC.
File Date
8/22/2023
File Number
812-15501
DoubleLine Funds Trust
DOUBLELINE ETF TRUST DOUBLELINE CAPITAL LP DOUBLELINE ETF ADVISER LP DOUBLELINE ALTERNATIVES LP
File Date
3/13/2025
File Number
812-15724
BondBloxx ETF Trust
BONDBLOXX ETF TRUST
File Date
12/4/2024
File Number
812-15665
BNY Mellon Investment Funds
BNY Mellon Investment Funds VII, Inc.
File Date
3/13/2025
File Number
812-15723
BlackRock Funds I
BlackRock Funds II BlackRock Funds V BlackRock Funds III
File Date
10/30/2024
File Number
812-15652
Aristotle Fund Series Trust
ARISTOTLE FUNDS SERIES TRUST
File Date
12/13/2024
File Number
812-15671
AMG Funds
AMG Funds I
AMG Funds II AMG Funds III AMG Funds IV AMG Funds LLC
File Date
7/2/2024
File Number
812-15599
Allspring Funds Trust
Allspring Funds Trust
File Date
6/20/2024
File Number
812-15670
AB Municipal Income Fund, Inc.
File Date
5/1/2024
File Number
812-15670
GMO Trust
Franklin Templeton ETF Trust
First Trust Series Fund
First Trust Exchange-Traded Fund
First Eagle Funds
Fidelity Hastings Street Trust
F/m Investments LLC
DoubleLine Funds Trust
DFA Investment Dimensions Group Inc.
Cash Account Trust: Deutsche DWS Funds
BondBloxx ETF Trust
BNY Mellon Investment Funds
BlackRock Funds
Aristotle Fund Series Trust
AMG Funds
Allspring Funds Trust
AB Municipal Income Fund, Inc.
GMO Trust
GMO Trust
File Date
5/23/2024
File Number
812-15577
Legg Mason Partners Investment Trust Franklin Advisors Inc. Franklin Advisory Services LLC Franklin Templeton Investment Management Ltd Franklin Templeton Fund Adviser, LLC
File Date
6/13/2024
File Number
812-15588
First Trust Series Fund
First Trust Advisors L.P. First Trust Portfolios L.P.
File Date
2/6/2025
File Number
812-15697
First Trust Exchange-Traded Fund
First Trust Exchange-Traded Fund First Trust Exchange-Traded Fund II First Trust Exchange-Traded Fund III First Trust Exchange-Traded Fund IV First Trust Exchange-Traded Fund V First Trust Exchange-Traded Fund VI First Trust Exchange-Traded Fund VII First Trust Exchange-Traded Fund VIII First Trust Exchange-Traded AlphaDEX Fund First Trust Exchange-Traded AlphaDEX Fund II
File Date
2/6/2025
File Number
812-15698
First Eagle Funds
FIRST EAGLE FUNDS
File Date
12/31/2024
File Number
812-15683
Fidelity Hastings Street Trust
Fidelity Management & Research Co LLC
File Date
10/24/2023
File Number
812-15517
F/m Investments LLC
RBB FUND, INC.
File Date
8/22/2023
File Number
812-15501
DoubleLine Funds Trust
DOUBLELINE ETF TRUST DOUBLELINE CAPITAL LP DOUBLELINE ETF ADVISER LP DOUBLELINE ALTERNATIVES LP
File Date
3/13/2025
File Number
812-15724
DFA Investment Dimensions Group Inc.
DFA Investment Dimensions Group Inc. Dimensional Investment Group Inc. Dimensional Fund Advisors LP
File Date
7/12/2023
File Number
812-15484
BondBloxx ETF Trust
BONDBLOXX ETF TRUST
File Date
12/4/2024
File Number
812-15665
BNY Mellon Investment Funds
BNY Mellon Investment Funds VII, Inc.
File Date
3/13/2025
File Number
812-15723
BlackRock Funds
BlackRock Funds I
BlackRock Funds II BlackRock Funds V BlackRock Funds III
File Date
10/30/2024
File Number
812-15652
Aristotle Fund Series Trust
ARISTOTLE FUNDS SERIES TRUST
File Date
12/13/2024
File Number
812-15671
AMG Funds
AMG Funds I
AMG Funds II AMG Funds III AMG Funds IV AMG Funds LLC
File Date
7/2/2024
File Number
812-15599
Allspring Funds Trust
Allspring Funds Trust
File Date
6/20/2024
File Number
812-15670
AB Municipal Income Fund, Inc.
AB Municipal Income Fund, Inc.
File Date
5/1/2024
File Number
812-15670
HARTFORD MUTUAL FUNDS, INc
INVESTMENT MANAGERS SERIES TRUST
JPMorgan Trust I
JPMorgan Trust II
File Date
11/25/2024
File Number
812-15663
Janus Investment Trust
JANUS INVESTMENT FUND
File Date
7/31/2024
File Number
812-15607
J.P. Morgan Investment Management Inc.
JPMorgan Trust I
JPMorgan Trust II
File Date
11/25/2024
File Number
812-15663
JPMorgan Trust I JPMorgan Trust II JPMorgan Trust IV J.P. Morgan Exchange-Traded Fund Trust J.P. Morgan Fleming Mutual Fund Group, Inc. J.P. Morgan Mutual Fund Investment Trust Undiscovered Managers Fund
File Date
11/25/2024
File Number
812-15662
MORGAN STANLEY INSTITUTIONAL FUND TRUST
Schwab Strategic Trust
The Charles Schwab Family of Funds Schwab Annuity Portfolios Schwab Capital Trust Schwab Investments Laudus Trust
File Date
6/17/2024
File Number
812-15589
Touchstone Funds Group Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
Shelton Funds
SPDR Series Trust
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
Metropolitan West Funds: TCW Funds
AB Municipal Income Fund, Inc.
Allspring Funds Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Additional Commitments
With respect to ETF share classes, ETF shares offered will not be marketed as a mutual fund investment. In some cases, this condition includes a stipulation that any advertising materials that describes the purchase or sale of Creation Units or refers to redeemability will also disclose that shares of the ETF class are not individually redeemable.
AB Municipal Income Fund, Inc.
Akre Focus Fund
Allspring Funds Trust
AMG Funds
PFS Funds
Madison Funds
Madison Funds
MADISON ASSET MANAGEMENT, LLC
File Date
3/21/2025
File Number
812-15727
ALPS ETF Trust
ALPS ETF Trust
ALPS VARIABLE INVESTMENT TRUST FINANCIAL INVESTORS TRUST ALPS ADVISORS, INC.
File Date
3/24/2025
File Number
812-15731
NuShares ETF Trust
Hotchkis and Wiley Funds
Aristotle Funds Series Trust
Morgan Stanley Institutional Fund Trust
T. Rowe Price Associates, Inc.
Lord, Abbett & Co. LLC (15681)
AMG Funds
Principal Funds, Inc.
Madison Funds
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Shelton Funds
SPDR Series Trust
Morgan Stanley Insitutional Fund Trust
Metropolitan West Funds: TCW Funds
Madison Funds
First Trust Series Fund
ALPS ETF Trust
Shelton Funds
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Madison Funds
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
First Trust Series Fund
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
Allspring Funds Trust
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Madison Funds
Shelton Funds
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Madison Funds
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
First Trust Series Fund
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
Allspring Funds Trust
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
Shelton Funds
Metropolitan West Funds: TCW Funds
Metropolitan West Funds: TCW Funds
TCW FUNDS, INC. TCW ETF TRUST TCW Investment Management Co LLC Metropolitan West Asset Management, LLC
File Date
3/20/2024
File Number
812-15556
AMG Funds
AMG Funds
AMG Funds I
AMG Funds II AMG Funds III AMG Funds IV AMG Funds LLC
File Date
7/2/2024
File Number
812-15599
Hotchkis and Wiley Funds
Hotchkis and Wiley Funds
NuShares ETF Trust
NuShares ETF Trust
AMG Funds
Morgan Stanley Institutional Fund Trust
Hotchkis and Wiley Funds
ALPS ETF Trust
Lord, Abbett & Co. LLC (15681)
T. Rowe Price Associates, Inc.
Palmer Square Funds Trust
Principal Funds, Inc.
Shelton Funds
SPDR Series Trust
Morgan Stanley Insitutional Fund Trust
Metropolitan West Funds: TCW Funds
First Trust Series Fund
Allspring Funds Trust
Shelton Funds
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Madison Funds
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
First Trust Series Fund
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
Allspring Funds Trust
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Madison Funds
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
First Trust Series Fund
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
Allspring Funds Trust
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
Shelton Funds
SPDR Series Trust
T. Rowe Price Associates, Inc.
Thornburg Investment Trust
Thrivent Mutual Funds
Tidal ETF Trust
Touchstone Funds Group Trust
Virtus Alternative Solutions Trust
Metropolitan West Funds: TCW Funds
Morgan Stanley Insitutional Fund Trust
Natixis Funds Trust
Northern Funds
NuShares ETF Trust
Palmer Square Funds Trust
PFS Funds
PGIM Investments LLC
PIMCO Funds
Principal Funds, Inc.
Professional Managed Portfolios: Akre Focus Fund
Schwab Strategic Trust
Segall Bryant & Hamill Trust
SEI Investments Global Funds Services
Franklin Templeton ETF Trust
GMO Trust
Guinness Atkinson Trust
Hartford Mutual Funds, Inc.
Hotchkis and Wiley Funds
Impax Funds Series Trust
Invesco Exchange-Traded Fund Trust
Investment Manager Series Trust
Janus Investment Fund
John Hancock Investment Trust
JPM (812-15662)
JPM (812-15663)
Lord, Abbett & Co. LLC (812-15680)
Lord, Abbett & Co. LLC (812-15681)
AB Municipal Income Fund, Inc.
ALPS ETF Trust
AMG Funds
Aristotle Funds Series Trust
BlackRock Funds
BNY Mellon Investment Funds
BondBloxx ETF Trust
Cash Account Trust: Deutsche DWS Funds
DFA Investment Dimensions Group Inc.
DoubleLine Funds Trust
F/m Investments LLC
Fidelity Hastings Street Trust
First Eagle Funds
First Trust Exchange-Traded Fund
First Trust Series Fund
Madison Funds
Shelton Funds